Lecture 3
Lecture 3
• Practice MCQs to ensure you understood and retained what was taught last lecture
• Updated schedule
• Discussion on post-lecture presentations
• De Novo pathway
• Going over some concepts from previous class like predicate devices, 510k and PMA
processes
• Different regulatory bodies worldwide
• About European union
• EU directives for medical devices
• Risk classification
• CE certification process
• Classification of medical devices in Singapore
• Regulatory framework of Singapore
Updated Schedule
Week Topics covered Notes Instruction mode
1 Introduction, what is and what is (not) a medical device, Role and Face-to-Face (F2F)
characteristics of a Regulatory professional
2 Project discussion, FDA classification of medical devices, FDA classification F2F
of Tissue Engineered product
3 Med device regulation in other jurisdictions (Singapore, EU) F2F
5 Project management, Ethics in device regulations (case studies) Group presentation 5-8 F2F
6 Salient features of devices, biocompatibility and design issues Group presentation 9-10 F2F
7 Commercialization of medical devices, audits, Post market obligations and Blended Learning
processes; surveillance and vigilance (recorded)
8 Guest Lecture (pending confirmation) Blended Learning/Zoom
9 Quality system regulation, compliance and risk analysis and management, Group presentation 11-15 F2F
product recall, global regulatory strategy
10 CA Quiz (MCQs and closed book) F2F
13 Project Final Presentations and Final report submission Gps 9-15 F2F
Schedule subject to change depending on availability of guest lecturers and travel needs
Post lecture
presentation details
Lets learn together
(post-lecture presentations)
Transcyte (Group 1)
Carticel (Group 2)
Apligraf (Group 3)
FocalSeal (Group 4)
Lets learn together
• Inspiration/unmet medical need
• Target audience
• Current standard of care for similar medical condition
• Commercial aspect/considerations
• Product details
• Principle and mechanism (how it functions)
• Clinical trials ?
• Issues with FDA ?
• Limitations and Side Effects
• The next better thing…
• Any other relevant and interesting aspect you wish to share
Rationale:
• To answer any questions you may have on the project/report
as well as on materials and contents covered thus far… All is
fair game…
• Provide additional avenues for shy (not so vocal) students,
who are unable to ask questions during regular lecture
sessions
• If any group prefers a different day/time, please let me know.
• It is optional, but only if anyone has any questions on the
materials covered thus far
• Every group to log in at their respective time
Extra feedback/consultation schedule- I
Groups Friday, 6th September Groups Friday, 6th September
1 11-11.10am 16 2-2.10pm
2 11.10-11.20am 17 2.10-2.20pm
3 11.20-11.30am 18 2.20-2.30pm
4 11.30-11.40am 19 2.30-2.40pm
5 11.40-11.50am 20 2.40-2.50pm
6 11.50-12 21 2.50-3pm
7 12-12.10pm 22 3-3.10pm
8 12.10-12.20pm 23 3.10-3.20pm
9 12.20-12.30pm 24 3.20-3.30pm
10 12.30-12.40pm 25 3.30-3.40pm
11 12.40-12.50pm 26 3.40-3.50pm
12 12.50-1pm 27 3.50-4pm
13 1-1.10pm 28 4-4.10pm
14 1.10-1.20pm 29 4.10-4.20pm
15 1.20-1.30pm
Zoom link:
https://nus-sg.zoom.us/j/3104119186?pwd=V2pCcXRCQ2hZUHZkRWE5ZjVYam5xdz09
Practice questions from
previous week
Some additional concepts from
last lecture
De Novo pathway
For new/novel (potentially ground breaking) medical
devices, which previously have not been designated a class
(as they are new), but are ascertained to be low to medium
risk, the De Novo pathway is appropriate…
Previously (prior to DeNovo) they were being placed in Class III, requiring
significant patient data and thus enhanced time to market…which FDA
felt was not appropriate
De Novo devices are those for which general and special “controls”
provide a “reasonable assurance” of the device’s safety and effectiveness,
even though there are no legally marketed devices of the same type
Substantial equivalence
• Both devices have same intended use
• New devices have same/very similar technology
CDRH submission cover A standardised cover sheet that can be used to record basic information on all pre-market
sheet submissions to the CDRH
Covering letter Identifies the device and gives a brief outline of the device
Table of contents
Statement of substantial Identifies reference device or standard and rationale for claiming equivalence/conformity
equivalence/conformity
Labelling Copies of labels, instructions for use or user manuals or other relevant information
Comparative information Data demonstrating equivalence and performance. May also include information from
predicate device to show equivalence of claims, etc.
Biocompatibility assessment Data establishing the biocompatibility of the materials
(if applicable)
Truthfulness and accuracy A signed declaration by a responsible person for the submission as to the truthfulness and
statement accuracy
Shelf life (if applicable) Data establishing the stability of the device, accelerated stress data are acceptable
Indication for use form Formal clarification of the indications for use, which will be made available to the public
510(k) Summary A summary of the submission, which will be made available to the public
Content of a PMA application
Table of contents summary Indications for use, device description, alternative practices, and procedures currently
available for the condition, marketing history (US or foreign), non-clinical laboratory
studies, clinical investigations, and overall conclusions.
Device description and Detailed drawings and description of device and methods used for manufacture and
manufacture control of the device.
Technical sections (pre- Non-clinical laboratory studies used to investigate microbiological, toxicological,
clinical and clinical data) immunological, biocompatibility, stress, wear, shelf life, and other characteristics of the
device.
Data from clinical investigations on human subjects, plus statements as regards
investigators, IRBs, and informed consent.
Device samples (on request) Provide samples of the device or a location where they may be tested by the FDA.
General
requirements
Safety Devices to be designed and manufactured so as not to compromise the safety of
patients or users. Any potential risks must be acceptable when weighed against the
benefits to the patient and be compatible with a high level of protection of health and
safety.
Effectiveness The devices must be designed and manufactured in such a way that they will deliver
their intended performance under the recommended condition for use.
Risk management The design and construction of devices must adhere to the following safety principles:
– eliminate or reduce risks as far as possible (inherently safe design and
construction),
– where appropriate take adequate protection measures in relation to risks that
cannot be eliminated (eg battery powered devices),
– inform users of the residual risks due to any shortcomings of the protection
measures adopted.
Stability The devices must retain their performance characteristics over their claimed lifetime
under the normal stresses associated with their use.
The devices must be designed, manufactured and packaged so as to maintain their
performance characteristics under the intended conditions of transport and storage.
Content of a PMA application
Devices used in combination with Consider the performance of the overall system
other devices or equipment
Information supplied by the Provide mandatory information on labels and instructions for use (specified according
manufacturer to directive/type of device). Use symbols on labels.
U.S. Classification of Medical Devices
Medical devices vary widely in their complexity and their degree of risk or benefits.
Thus, U.S. FDA places all medical devices into one of three regulatory classes based
on the level of control necessary to assure safety and effectiveness of the device.
Of the appx 1,700 classified devices, about 45% are Class I, 47% are Class II and 8%
are Class III.
• USA: US Food and Drug Administration (FDA)
• Singapore: Health Science Authority (HAS)
• Australia: Therapeutic Goods Administration (TGA)
• Canada: Health Canada
• China: National Medical Product Administration (NMPA)
• Europe: European Medical Agency (EMA) and European Commission
• Japan: Pharmaceuticals and Medical Devices Agency (PMDA)
List of member states of the European Union
1981 Greece
2004 Czech Republic, Cyprus, Estonia, Hungary, Latvia, Lithuania, Malta, Poland,
Slovak Republic, Slovenia
2007 Bulgaria, Romania
2013 Croatia
The European Union member countries facilitate the free movement of goods (including medical devices).
Medical devices bearing the CE mark are cleared in the European Union market. The European Economic Area
(EEA) was established on 1 January 1994 following an agreement between the member states of the European
Free Trade Association (EFTA) and the European Community: Iceland, Liechtenstein and Norway are allowed to
participate in the EU’s Internal Market without a conventional EU membership. In exchange, they are obliged to
adopt all EU legislation related to the single market (including for Medical Devices). One EFTA member,
Switzerland, has not joined the EEA; CE marking of Medical Devices is, however, recognized in Switzerland by
means of a Mutual Recognition Agreement (MRA) between the EU and Switzerland.
Medical Devices Directives
The European Directives have to be transposed into national law by each member state in
order to integrate the content of these directives into laws and regulations without major
modification (Changes which conflict with EU Directive are not acceptable)
Because the regulations are harmonized, MD bearing the CE marking may circulate freely through
out EU (although some countries may have additional conditions/barriers to market)
Transition from EU MDD (medical device
directive) to EU MDR (medical device
regulation)
• When they are of higher risk and/or intended to be used by home user for
self-testing, they require a premarket design examination from a notified
body.
EU regulations: Competent Authority (CA)
• The manufacturer must ensure that it is manufactured to meet or exceed the required standards
of safety and performance.
• The legal manufacturer is responsible of all the operations necessary to design, manufacture, label
and package the product throughout its lifecycle from design to distribution to the final customer.
The legal manufacturer is responsible to choose the notified body and affixing the CE mark on the
product once it is obtained.
• The manufacturer has an obligation to ensure that a product intended to be placed on the
Community market is designed and manufactured, and its conformity assessed, to the essential
requirements in accordance with the relevant provisions.
• The manufacturer may use finished products, ready-made parts or components, or may
subcontract these tasks. However, LM must always retain the overall control and have the
necessary competence to take the responsibility for the product
Risk base EU classification of Medical Devices
Not to say that the product is ready for marketing but rather the
product conforms to established directives/regulations
Medical Device Classification By the Legal Manufacturer
Technical documentation
review by notified body
Batch verification
by notified body Steps to CE
Quality management system
verification by notified body
marking
CE mark certificate delivered
by notified body
Class I
Class Is, Im, IIa, IIb, III
It is a bit more complex but I have tried to put it in simpler terms to facilitate your understanding
Some fundamental points for
comparing EU/US Medical Device
Legislation
36
Purpose
• EU • USA
• European Treaty • To promote inter-state trade
• Requirements to allow medical • Requirements to allow medical
devices to be traded across the devices to be traded across
Member States without trade individual States
barriers
Authorities
• Legal authority: 28 Competent • Legal authority: FDA
Authorities
• Approval (PMA): FDA
• Vetting compliance with ER: 60
• Notification (510k): FDA
Notified Bodies
• Authority which can prosecute
• Authority which can prosecute
you: FDA
you: Competent Authorities
37
Content
EU USA
• Sets out Essential Requirements • Sets out Pre-Market Approval
(ER) which all devices must meet (PMA) requirements and confers
• Lists procedures through which Pre-Market Approval
manufacturers can demonstrate • Sets out Substantial Equivalent
compliance with ER (SE) process and issues SE
• Manufacturer makes Declaration Notification
of Conformity
Routes to market
• EU: seven different routes • PMA (Pre market approval)
covering • 510(k) Notification
– Active implantables
– Medical devices
– In vitro diagnostic medical
devices 38
Process
EU USA
• Manufacturer (M) classifies • FDA specifies classification
device (four classes) • FDA specifies route - PMA or 510(k)
• M chooses route • PMA: FDA specifies tests etc to be
• M does work to demonstrate carried out
compliance with ER • 510(k): M demonstrates this device
like another already on the market
• Notified Body assesses
• FDA writes Approval (PMA) or
compliance Notification (510k)
• M writes DoC
39
Compliance (simplified!)
EU USA (510 k)
• Notified Body carries out on-site • FDA examines technical
audit submission
• Checks QMS & Tech File • Issues ‘notification letter’
• Issues certificate • Marketing product
• Declaration of Conformation by M • At sometime later (2-4 years) on
• Marketing product site inspection of QMS
• Post market surveillance required
40
Singapore: Medical Device
Regulatory System
HSA (Health Science Authority)
Formed April, 2001 and comprises of:
• Health product regulation group
• Blood services group
• Applied science group
In 2002, HSA introduced the Voluntary Product Registration Scheme and post-
market monitoring and surveillance program for medical devices in the Singapore
market. With the passage of the Health Products Act 2007 in February 2007, HSA
implemented the Health Products (Medical Devices) Regulations to further
strengthen the control of medical devices in local market.
Implementation phases of the regulatory control
Imposition of duties Acceptance of license Only licensed dealers Unless authorized by HSA,
and obligations on application of parties shall manufacture, all classes of MDs are
dealers: dealing with MD import and supply MDs prohibited from supply
• Report product Acceptance of unless authorized by (Class A, B, C, D) MDs
defects and AEs Registration of Class HSA or listed on the licensed under Radiation
• Recall product upon C, D (Transition Transition list, all Protection Act, NEA —
HSA instructions list/registered) Unregistered Class C, D August 1, 2011
• Keep distribution MDs are prohibited
Records from supply
Classification of Medical Devices (Classes A,
B, C, and D)
Principle
Regulatory control is proportional to the level of risk associated with a medical
device, which increases with higher degree of risk involved. Therefore, medical
devices are classified on the basis of their risk to patients and users substantially
on its intended purpose and effectiveness of the risk management techniques
applied during design, manufacture and use.
Classification
Various factors contribute to the risk classification of medical devices, which
includes:
• duration of medical device contact with the body
• degree of invasiveness
• delivery of medicinal products or energy to the user
• intended to have biological effect on the user
Risk classification system for medical
devices In Singapore
Submission in Common Submission Dossier Template (CSDT) is not required for Class A
medical devices.
• Abridged method:
• If it is approved in either; USA, EU, Australia, Japan, Canada
Country Regulatory agency/body National healthcare
policies/laws/regulations
US FDA Food, drug and cosmetics act and its
• Center for devices and radiological amendments
health (CDRH)
The level of complexity and burden on medical device market clearance process is
defined by the controls established in the country of interest
Some take home massages…
• Device classification for EU and Singapore is also risk based like FDA;
only that the nomenclature is little different
• Of the appx 1,700 FDA classified devices, about 45% are Class I, 47%
are Class II and 8% are Class III